Case 1:15-cv-00311-RGA Document 108 Filed 03/25/16 Page 1 of 3 PageID #: 3183
`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 1 of 3 Page|D #: 3183
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.,
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`Defendant.
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`V.
`
`ELECTRONIC ARTS INC.,
`
`Defendant.
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`V.
`
`TAKE~TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
`
`Defendants.
`
`
`
`
`
`\/\./\/\/\./\/\/\/xzxyyz\.z\./\/\/\/\/\/\.x\/\/\_/g/\./\./\/\/\_/\/
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`CA. No. 15-228 (RGA)
`
`PUBLIC VERSION
`1
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`CA. No. 15~282 (RGA)
`
`C.A. No. 15-311 (RGA)
`
`DECLARATION OF NATASHA RADOVSKY IN SUPPORT OF
`ACCELERATION BAY’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
`
`Public Version Dated: March 25, 2016
`
`
`
`Case 1:15-cv-00311-RGA Document 108 Filed 03/25/16 Page 2 of 3 PageID #: 3184
`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 2 of 3 Page|D #: 3184
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`1, Natasha Radovsky do declare and state as follows:
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`1.
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`I have personal knowledge of the facts stated herein and can testify competently
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`to those facts.
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`I make this declaration in support of Plaintiff Acceleration Bay LLC’s
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`(“Acceleration Bay”) Opposition to Defendants’ Motion to Dismiss.
`
`2.
`
`Director, Global Patent and Technology Licensing, Boeing Intellectual Property
`
`Licensing Company. Responsible for leading the team that is in charge of rnonetization on
`
`Boeing’s ll’ assets. Specifically: oversee [P deal~tearn negotiations,
`
`technology and patent
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`monetization strategies; patent and technology licensing; patent
`
`transactions (acquisitions /
`
`divestitures);
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`contract negotiations;
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`structuring patent
`
`and technology sale
`
`/
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`licensing
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`agreements;
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`building
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`strategic
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`partnerships;
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`business
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`development;
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`complex
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`project
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`management; IP deal structure and negotiations; market research and company financial analysis
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`related to supporting patent and technology portfolio licensing campaign.
`
`3.
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`I was personally involved with the negotiations between Acceleration Bay and
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`Boeing over the December 10, 2014 Patent Purchase Agreement (the “Purchase Agreement”).
`
`I
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`am also personally familiar with Boeing’s commercial activities, including its customers and the
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`products and services that it provides.
`
`4.
`
`
`
`
`
`Case 1:15-cv-00311-RGA Document 108 Filed 03/25/16 Page 3 of 3 PageID #: 3185
`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 3 of 3 Page|D #: 3185
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`
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`7.
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`Boeing is among the largest global aircraft manufacturers and defense contractors
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`in the world and designs, manufactures, and sells a variety of products, including airplanes, space
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`' rockets, satellites and very sophisticated training simulations, as well as related services,
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`including training. Boeing does not design or manufacture mass—Inarket entertainment video
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`games.
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`8.
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`Boeing sells and leases training simulations, and provides training services using
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`simulations. Boeing’s simulations are very expensive and sophisticated physical devices and
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`software used to train pilots, astronauts and military personnel. Boeing’s simulations replicate
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`actual conditions in an airplane cockpit or spacecraft for training purposes, and are also used to
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`develop and test real~world aircraft and aerospace products, such as validating the performance
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`of missile defense systems.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct. Executed on March 15”‘, 2016, in Huntington Beach, California.
`
`//
`,
`»,~’. /32 .[” /5//\*~*““"M
`Natasha Ra<{ovsky
`
`fl
